Republic of the Philippines

Municipal Trial Court

Angeles City

Rico, Leilani, Myrna

Complainants.

-Versus- CC No. xxxxx

For: Reckless
Imprudence Resulting in
Damage to Property and
Physical Injuries
Francis Morales
Respondent.

x---------x
COUNTER-AFFIDAVIT

I, Francis Morales, Filipino, of legal age, and a resident of xxx, xxx, after
being sworn in accordance with law , do hereby depose and state that:

1. I am the Francis Morales (herein referred to as “Respondent”) in this

case for alleged commission of a crime of Reckless Imprudence
Resulting in Damage to Property and Physical Injuries under Article
365 of the Revised Penal Code;
2. The complaint is in connection with the injuries and damages
sustained by Rico, Leilani, Myrna and Albert Vitali (hereafter referred
to as “Complainant”), resulting from an accident that happened at
3:00 a.m. on May 15, 2013 along the road of Sto. Rosario Street,
Angeles City;
3. I recognize Number 7 as fact and specifically deny Number 8 of the
stated facts of the complaint-affidavit of the complainants
4. That contrary to the statement of the complainants, I was on my way
home with my son. Traversing the road of Sto. Rosario Street bound
to San Fernando at the right speed occupying the inner lane. When
suddenly the right side of the jeepney driven by Rico hit the Delica
Van driven by me.
5. I, along with my son suffered injuries in the collision and were
brought to the Sacred Heart Medical Center for treatment.
6. Likewise, the Delica Van sustained extensive damages

City of Angeles, Philippines, (Date)

 Francis Morales
Respondent

SUBSCRIBED and SWORN to before me, the undersigned counsel,

this x day of x, xxxx in the City of Angeles, Philippines. I hereby certify that
I have personally examined the above-named affiant and that I am satisfied
that the foregoing statements were given by him voluntarily and of his own
free will.

Notary Public